Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter III: A4.3 to […]
TP Lecture week 11 – Comparability analysis Part II Read Post »
Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter III: A1 to
TP Lecture week 10 – Comparability analysis Part I Read Post »
Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter II: Part 3
TP Lecture week 9 – TP methods Read Post »
Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter II: Part 3
TP Lecture week 8 – TP methods Read Post »
Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter II: Part 1
TP Lecture week 7 – TP methods Read Post »
Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter 1: Section
TP Lecture week 6 – Functional analysis Read Post »
Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter 1: Section
TP Lecture week 5 – ALP and introduction to comparability Read Post »
Listen to the following intro to TP and TP cases (where short summary of lecture is part of the week’stutorial):
TP Lecture week 4 – Legal Framework Read Post »
Download a copy here: US TP 2018 Coca Cola case petitioner’s pre-trial memorandum To understand the applicable TP principles applicable
US TP the pre-trial memorandum in the Coca-cola intangibles case and various articles Read Post »
I wrote a book on tax risk management that includes tax and strategy. It is called TAX INTELLIGENCE and is
JOINT STATEMENT OF THE COMMISSIONERS GENERAL AND HEADS OF DELEGATION OF SOUTH AFRICA, BOTSWANA, LESOTHO, MOZAMBIQUE, NAMIBIA, SWAZILAND AND ZAMBIA
SA, neighbouring countries discuss beefing up tax enforcement Pretoria – The South African Revenue Services (SARS) has convened a forum
S.Africa: And neighbouring countries discuss beefing up tax enforcement Read Post »
Choose the track that fits your practice focus. All programmes are practitioner-taught, cohort-based, and validated by Middlesex University.
| Dimension | Transfer Pricing | International Taxation | South African Tax Law |
|---|---|---|---|
| Jurisdictional audience | Global audience, covers all jurisdictions | Global audience, covers all jurisdictions | South Africa specific, relevant to SADC region |
| Ideal for | TP managers, advisors, in-house tax teams, analysts moving into TP | Advisors and managers dealing with cross-border rules, treaties, planning | Practitioners working with the SA Income Tax Act, cases, compliance |
| Core focus | Methods, comparables, DEMPE, documentation, audits, dispute defence | Treaties, source vs residence, anti-avoidance, PE, relief from double tax | Statutory interpretation, case law, assessments, objections, local practice |
| Primary tools | OECD TP Guidelines, UN Manual, BEPS Actions 8–10, 13, case law | OECD and UN Models, MLI, BEPS 1.0 and 2.0, domestic rules, cases | Income Tax Act, SARS practice notes, Tax Administration Act, SA cases |
| Assessment style | Case-based assignments, file reviews, short written defences | Problem questions, treaty interpretation, position papers | Problem questions, statutory analysis, case commentary |
| Typical outcomes | Build defensible TP files and strategies, improve audit readiness | Design cross-border structures within rules, mitigate double tax | Apply SA tax law accurately, manage reviews and disputes |
| Entry point | Start with PG Certificate, progress to PG Diploma, then MSc, or enter later with suitable experience or credits. | ||
| Award | Best for | What you achieve | Assessment highlights |
|---|---|---|---|
| PG Certificate | Foundation to intermediate upskilling | Core concepts, frameworks, and applied techniques | Short case write ups, timed responses, applied tasks |
| PG Diploma | Expanding technical depth and application | Advanced analysis, risk management, documentation quality | Integrated case assignments, policy memos, oral defence |
| MSc | Leaders and specialists building authority | Capstone project and research backed practice outcomes | Research project, viva or presentation, publishable summary |
Practical, practitioner-led certificates designed for immediate on-the-job application. Each course can stand alone or act as a pathway into our postgraduate tracks.
| Dimension | Conducting a Transfer Pricing Trial | Effectively Managing Tax Teams | Indirect Taxation | Tax Risk Management |
|---|---|---|---|---|
| Jurisdictional audience | Global audience | Global audience | Global audience, with local adaptation | Global audience |
| Ideal for | In-house tax, TP managers, litigators, advisors preparing for audits, ADR, trial | Heads of tax, managers, team leads, controllers, emerging leaders | VAT, GST, customs, finance managers, AP, AR, compliance specialists | Tax managers, risk officers, controllers, advisors building governance |
| Core focus | Case theory, evidence files, expert reports, witness prep, courtroom strategy | Operating models, KPIs, workflows, stakeholder management, coaching | VAT design, place of supply, input credits, exemptions, WHT interactions | Risk identification, controls, documentation, audit readiness, dispute playbooks |
| Delivery mode | Online, live sessions plus guided self-study | Online, live sessions plus guided self-study | Online, live sessions plus guided self-study | Online, live sessions plus guided self-study |
| Duration | 16 weeks, part-time | 16 weeks, part-time | 16 weeks, part-time | 16 weeks, part-time |
| Outcomes | Confident litigation preparation and defence for TP disputes | Stronger execution, clear roles, measurable team performance | Reduced VAT errors, better cash flow, fewer surprises at audit | Structured governance, fewer findings, faster dispute resolution |
| Prerequisites | TP fundamentals recommended | Supervisory experience helpful | Basic VAT knowledge helpful | General tax experience helpful |
| Pathway | Progress to PG Certificate in Transfer Pricing | Progress to Mechanics of Leading Tax Teams, PG Certificate (leadership) | Progress to PG programmes, International Tax or SA Tax Law | Progress to PG Certificate in International Taxation or Transfer Pricing |
| Assessment | End of module progress assessment 5000-word assignment if PG-Cert option elected |
End of module progress assessment 5000-word assignment if PG-Cert option elected |
End of module progress assessment 5000-word assignment if PG-Cert option elected |
End of module progress assessment 5000-word assignment if PG-Cert option elected |